It has been just over 2 years since Encana ceased operations at the Pratt site in Erie due to unresolved noise violations. Now Crestone Peak Resources believes it can resume drilling at the site without encountering the same problems.
Let’s revisit recent history: In December 2014 drilling at the Pratt site consistently exceeded 65 decibels of C-level noise. Despite multiple attempts at mitigation, Encana could not reduce the noise to acceptable levels. Furthermore, while it normally only takes 10 to 14 days to complete the drilling process for one well, it took operators at the Pratt site nearly 30 days to finish one well. During a town hall meeting in 2015, representatives from Encana explained that an “anomaly” at the site made drilling more difficult, which is why it took longer than usual to complete the drilling process.
According to the Colorado Oil and Gas Conservation Commision (COGCC) database there were 40 complaints from residents near the Pratt location between 12/1/14 and 12/29/14. Here is the response from Matt Lepore (Director of the COGCC) to all residents who filed noise complaints: COGCC letter to residents. Mr. Lepore also addressed Mayor Harris, the Board of Trustees, and the general public during a town hall meeting in January 2015 which can be viewed here: Matt Lepore addresses Erie Town Hall. Both in his letter to residents as well as his public address, Mr. Lepore told Erie homeowners that if Encana decided to return to the Pratt location, the COGCC would establish “around the clock noise monitoring during drilling operations” and Encana would need to drill in stages, successfully drilling the surface casing without exceeding noise limits prior to drilling deeper.
Fast forward to 2016: In July Encana sold its Denver Julesburg Basin assets in Colorado to Crestone. On Friday January 27, 2017 the Town of Erie notified residents via email that Crestone plans to resume drilling operations at the Pratt and Waste Connections sites in March. By Thursday February 2 residents were already experiencing increased truck traffic and noise from site preparations.
After receiving the email notification I decided to stop by the Crestone office in downtown Erie. I hoped to talk with someone from Crestone in-person, as I wanted to know if they had any idea of the quagmire they would be walking into by resuming drilling at the Pratt location. I carried with me a copy of a Denver Post article from 2015 that details the messy history of the noise violations at the Pratt site. I wanted to know if Encana had been forthcoming with Crestone about the fact that they had spent $250,000 on attempting to mitigate the noise, yet in the end cut their losses and pulled out. But I couldn’t find Crestone’s office. The building has a large sign in the front yard that says Crestone on it, but all of the doors to the building have signs for different law firms. I later learned that the Crestone office is on the second floor and you have to enter through one of the law firm doors. It wouldn’t have made a difference though. It turns out that Crestone’s office is only available to the public by appointment.
I also called Crestone three times beginning that same day. Twice I left friendly voicemail messages requesting that someone call me back since I am a resident of Erie who lives near one of the sites they will soon be drilling and I have a few questions. On Friday Feb 3 I actually reached someone. However he told me that the office was closed, as it always is on the 1st and 3rd Fridays of the month. He took my name and phone number and assured me that someone would call me back on Monday. That call never came. I have also emailed Crestone twice – and no one has responded other than to give me the link to the telephone town hall meeting.
In the meantime, I emailed our Mayor and Board of Trustees (BOT) several times about my concerns. Mayor Harris eventually responded, apologized for the delay, and let me know that she and the BOT were concerned too. She informed me that the BOT had an executive meeting scheduled with their Oil and Gas Special Counsel set for Tuesday February 14.
I also reached out to Matt Lepore (Director of the COGCC) and was surprised to receive a quick response. However his explanations fall short of his previous promises. The entire email exchange follows (although I removed my name and address for privacy):
Friday February 10, 2017
Dear Matt Lepore,
In 2014, Encana commenced drilling at the Pratt site in Erie and ran into “unprecedented” noise issues that could not be resolved. At a town hall meeting, you apologized for the COGCC’s slow response, and said that in order for Encana to return to the Pratt site, they would first have to demonstrate that the noise problems had been solved. Furthermore, you stipulated that they would have to drill several test wells before drilling deeper.
In the interim, Crestone bought Encana. Crestone has given Erie residents notice that they will resume drilling at the Pratt and Waste Connections sites in March 2017. Yet we have been given no assurances that the noise issues have been resolved. My question for you, is will you uphold your commitment to Erie residents and require that Crestone prove that they will not create the same debacle at the Pratt site we endured before?
Thank you for your prompt attention to this important matter.
(My full name and address)
Friday February 10, 2017
Mr. (my last name):
Thank you for your email.
Crestone Peak has taken a number of steps to ensure their operations will
be quieter than Encana’s were in late 2014. Crestone will be using
electric power for the drilling rig at the Pratt location. In addition,
they have studied other sources of noise associated with their drilling
rigs and have taken measures to dampen those sources. The rig that will
be used to drill the Pratt location wells is currently being used nearby
and Crestone is monitoring the rig’s performance so it can make
modifications if necessary.
Crestone is addressing the “test well” issue by using the same rig that
will be used for Pratt at another location to gauge its performance. In
addition, Crestone Peak will be taking “core” samples prior to drilling to
ascertain whether there are abandoned coal mine shafts in the area they
are drilling, which contributed to the complications they encountered in
Matthew J. Lepore
Saturday February 11, 2017
Dear Matt Lepore,
I really appreciate your prompt and thorough response. I do however have a couple of additional concerns.
Encana and the COGCC initially explained to Erie residents that the problems encountered at the Pratt site were an “anomaly” with no easily identifiable cause. So when you say that Crestone is testing their electric rig at another location and that is therefore a reasonable predictor of how the rig will perform at the Pratt location, I am more than a bit skeptical. Since the problems at the Pratt site were believed to be site-specific, results from “test” drilling at another site nearby do not translate.
At the very least, I implore the COGCC to set up noise monitors in nearby homeowners’ yards prior to the start of any drilling so that problems can be identified immediately. The COGCC’s delay in 2014 caused undue suffering to Erie residents and should not be repeated.
Furthermore, I request that air quality monitoring be set up at the Pratt and Waste Connections sites at the time drilling commences. The complaint that I personally filed in 2014 was due to chemical odors (and my experience of light-headedness as a result) that occurred during flaring at the Pratt site. Forty eight hours later the COGCC investigated; of course by then, flaring was no longer taking place and air quality had improved to a level where no violation was identified. This is a completely ineffective way to protect the health and safety of residents who live in proximity to oil and gas operations. Proactive air quality monitoring would go a long way in re-establishing some public trust in the COGCC.
Thank you again for your time and attention.
(my full name)
Sunday February 12, 2017
Ms. (my last name):
The referenced anomaly were subsurface coal mine shafts from days of yore. Crestone Peak will be drilling “core” samples prior to drilling their wellbores in an effort to identify and avoid any such shafts this time around. The electric motors and other noise mitigation measures they have taken should translate from one location to the next, although other variables, including topography and wind speed and direction, can effect sound significantly.
I will confirm this, but I am almost sure Crestone Peak will be monitoring sound levels continuously during drilling.
Although COGCC does have jurisdiction over odors from oil and gas operations, air quality monitoring detects specific constituents in the atmosphere; there are not “odor monitors” to the best of my knowledge. Monitoring for air pollutants falls under the jurisdiction of the Colorado Department of Public Health and Environment, Air Pollution Control Division.
Matthew J. Lepore
I forwarded my email exchange to Mayor Harris and the BOT. It is frustrating that while no one ever verified that the rig itself was the source of the excessive noise at the Pratt site (as there was never a public report or press release revealing that the COGCC or Encana had determined a cause) we are now supposed to accept Mr. Lepore’s conclusion that use of an electric rig will solve the noise issue. Plus, if Crestone is doing their own noise monitoring which Mr. Lepore is “almost sure of”, we are supposed to believe that they will report themselves and cease operations if they are exceeding the limits?
I have to applaud Mr. Lepore’s use of the phrase “days of yore” as it is difficult to work that expression into modern day communication and it lends a patronizing tone to his comments. Let’s consider for a moment the likelihood that hidden mine shafts would make drilling more difficult. Erie is an old coal mining town and is littered with subsurface mines. In fact, land subsidence is a known entity here that results from collapse of underground mine shafts. So is it really plausible that subsurface mine shafts would allow the ground to support the weight of a large, heavy drilling rig and yet make it incredibly difficult to drill through without collapse and subsidence? Maybe the coal mine shafts from bygone days are filled with concrete – or made out of diamonds.
There is a lot more information to dissect here – like the fact that the COGCC will investigate “odors” but has no jurisdiction over quantifiable, objective measures of air quality. There is also this past week’s disastrous “Telephone Town Hall Meeting” with Crestone representatives to address. But that discussion will require its own separate blog post.
For now, I would like to leave you with the most interesting result of my review of Mr. Lepore’s communications. Back in early 2015, he mentioned that the COGCC was collaborating with researchers at Colorado State University to evaluate noise produced by drilling and fracking operations. The study that he refers to has since been made public, and their findings are quite damning for the industry in terms of placing oil and gas activities near residential areas. You can read the entire study here: CSU Noise Characterization of Oil and Gas Operations 2016.
The abstract concludes with the following statements:
“At 117 yards from the noise source, all drilling, hydraulic fracturing and completion sites exceeded 65 dBC.
Current sound wall mitigation strategies reduced sound levels in both the A- and C weighted scales. However, this reduction in noise was not sufficient enough to categorize drilling and hydraulic fracturing sites as compliant with the current COGCC noise regulations.”
Essentially, at ~350 feet (117 yards) from the operation (the point as which the COGCC is supposed to measure sound levels), drilling, fracking and completion activities typically exceed the noise limits allowed by the COGCC. Yet it is okay for these operations to be so close to our homes? I think this study provides even more fuel for a citizen driven lawsuit against the State of Colorado, for knowingly jeopardizing the health and safety of its citizens through inadequate regulation of the oil and gas industry.